RAJASEKHAR NAIDU GALLA,TIRUPATI vs. DCIT., CIRCLE-1(1), TIRUPATHI

ITA 917/HYD/2025Status: DisposedITAT Hyderabad28 January 2026AY 2020-21Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the assessee had a right to purchase the property, and its relinquishment constituted a transfer of a capital asset. The Assessing Officer had conducted proper inquiry by calling for specific details, and the view taken by the AO was a possible view, thus not making the assessment erroneous.

What were the facts?

The assessee declared a long-term capital loss from the relinquishment of rights in a property. The Principal CIT initiated revision proceedings under Section 263, alleging the assessment order was erroneous and prejudicial to revenue due to lack of proper inquiry regarding the capital gains calculation and the nature of the transaction.

What were the issues?

Whether the Principal CIT erred in invoking Section 263 by deeming the assessment order erroneous and prejudicial to revenue, and whether the AO conducted adequate inquiry regarding the capital gains computation.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 144B,Section 2(14)

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, Hyderabad “B” Bench, Hyderabad

For Appellant: Shri K. Vinoth Kannan, Sr

PER MANJUNATHA G., A.M : This appeal filed by the assessee is directed against the order of the learned Principal Commissioner of Income Tax, Tirupati, dated 28.03.2025, passed under Section 263 of Income Tax Act,

2 Rajasekhar Naidu Galla

1961 (for short “the Act”) and pertains to the assessment year 2020-21. 2. The grounds raised by the assessee read as under :

“1. T

The order continues below.

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